Please find below and attached the submissions in relation to the Crown Commercial Service (CCS) Language Services Framework Agreement (FWA) made on behalf of the following representative bodies which are members of Professional Interpreters for Justice (PI4J):

· Association of Police and Court Interpreters (APCI)
· Chartered Institute of Linguists (CIOL)
· Cymdeithas Cyfieithwyr Cymru (CCC)
· Institute of Translation and Interpreting (ITI)
· National Register of Public Service Interpreters (NRPSI)
· National Union of Professional Interpreters and Translators, part of Unite the Union (NUPIT)
· National Union of British Sign Language Interpreters, part of Unite the Union (NUBSLI)
· Society of Official Metropolitan Interpreters UK Ltd (SOMI)

We understand that the CCS has informed the National Police Chiefs’ Council (NPCC) that interpreters and their representative bodies are ‘on-board’ and support their Language Services FWA.

This is not the case.

On 25 March 2015 PI4J sent an email to the CCS outlining our position with regard to the CCS Language Services FWA.

Our correspondence made it very clear that we cannot support any arrangements or FWA which does not fully take into consideration all our submissions in respect of minimum professional qualifications for Public Service Interpreters (PSI) and BSL/English Interpreters, Deaf interpreters and Sign Language translators, mandatory NRPSI/NRCPD/SASLI registration, and independent regulation and quality and performance auditing.

This FWA has not incorporated all our suggestions and concerns into the specifications and we do not believe it will fulfil the language demand and standards requirements for the Police Forces and other agencies serving the Criminal Justice System.

Just as important are sustainable and fair rates of pay for interpreters, which do not discriminate between spoken language and BSL interpreters.

We believe that a system of competitive tendering where the lowest bidder wins will lead to unfavourable terms and conditions for legal interpreters, who can and will transfer their expertise to other areas of work as they are self-employed independent professionals.

Interpreters have demonstrated this for the last four years by their ongoing refusal to work for the agency to which the Ministry of Justice outsourced their court interpreting service through a commercial contract which has been widely discredited, resulting in massive disruption and a market exit of skilled and experienced interpreters.

They have also refused to work for other low-paying agencies which show little regard for quality and standards.

The message is simple: unless interpreters are offered sustainable rates, they will boycott this contract too.

Interpreters are used by the police services for essential communication with the public, 95% of which is of an evidential nature for victims, witnesses and suspects and so is required to be of the highest standard. Failure to achieve the required standard will result in increased risks of, at the very least, unacceptable delays in justice and at worst, miscarriages of justice.

Either way it will be accompanied by increased costs (e.g. keeping people in custody or having to release suspects due to a lack of interpreters) and reductions in public confidence and satisfaction.

The only way to ensure quality of result for the victim and fairness for the perpetrator in any case is having good-quality interpreters, resulting in improved integrity of investigations and trials, better treatment of victims, witnesses and detainees, compliance with legal obligations, and good race relations.

We maintain that there could be more savings in the long term by investing in the establishment of a central government agency, which is “not for profit” and therefore does not seek to gain a pecuniary advantage from interpreters’ work. This may achieve a streamlining of the system and thereby utilise interpreter services in a more organised and efficient way—dealing with the process of identifying and booking individual interpreters, as well as with the payment process.

With this in mind, we urge you to review the Police National Guidance on the use of this and other similar framework agreements and/or contracts, and consider the alternative solutions which PI4J presents in the attached letter to Kent Police regarding their recent decision to outsource interpreting services to thebigword.

We also attach for your information a copy of our letter to the CCS as well as the PI4J Statement of Objectives, which clearly outlines our position.

We understand that procurement arrangements are left to the discretion of chief officers when determining an operational matter such as the individuals or organisations they use to provide services for their forces.

We therefore request that you please forward this email to all NPCC Members and other interested parties, in order to inform them of our submissions.

Price competitive tendering has already been introduced into the criminal justice system. Court interpreting services were put out to tender. The cheapest tender won. Interpreting services in court since this was introduced are shambolic. It is common for the court and lawyers to wait all day at court for an interpreter to arrive. In a recent case a crown court was kept waiting for two days because the company providing interpreting services could not send an interpreter to court. Most interpreters who provided a professional service before refused to work for the low pay offered by the company. The quality of interpreters plummeted. The government have just bailed out the company who provides court interpreting services with tax payer’s money. More tax payer’s money has been wasted in keeping courts waiting for interpreters to attend.

This is the example that the government seeks to follow by introducing tendering to police services.

In a new report, the Association of Translation Companies(ATC) has demanded a major overhaul in how the public sector buys language services, so that “achieving value for money should not be at the expense of ensuring a high quality service.” According to the report, “the public sector is one of the largest users of language services in the UK” and “such services are essential for millions of people.”

At a time when the Crown Commercial Service and the Ministry of Justice are in the process of procuring language services worth hundreds of millions of pounds of taxpayers’ money for government departments the report points out that achieving value for money should not be at the expense of ensuring a high quality service, whilst a failure to provide satisfactory language services – translation, interpreting and signing – can cause extra cost to the public purse.

According to the ATC, a focus on saving money at the expense of service quality has also led to a ‘critical shortage’ of skilled language professionals unwilling to work in the public sector, meaning the government may struggle to meet its future language service requirements.

The users of interpretation services are among the most vulnerable communities in the country. Coupled with the fact that most service providers are self-employed independent professionals, both providers and beneficiaries are in a vulnerable position that is easy to exploit.

It was a fatal incident due to the provision of an interpreter for the wrong language and gender and cultural insensitivity on the part of the court system at the time that in part led to the creation of a National Register of Public Service Interpreters in 1994, and not market forces.

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